Moon v. Calvin: Five-Step Analysis in Determining a Disability

Moon v. Calvin, a case from the U.S. District Court for the Seventh Circuit, involved a claimant who was 26-years-old at the time she filed for Social Security Disability Insurance (SSDI) benefits. She is a mother who has worked in the past as a cashier, bank employee, and as a nursing assistant.

As your Boston disability lawyer understands, being disabled can mean different things to different people. This claimant had a long history of health problems, including joint problems, back pain, sleep apnea, and migraines, and she also suffers from depression. According to doctors, most of her health conditions are a result of the fact that she is 5’5″ tall and weighs over 400 pounds.

When claimant was diagnosed with migraines, she was prescribed two drugs but chose not to take them due to worries of side effects. She was eventually prescribed two new drugs, which were being taken at the time of her hearing before an administrative law judge (ALJ). The ALJ is employed by the Social Security Administration (SSA), which, among its other responsibilities, oversees the SSDI program.
During her benefits appeal hearing, claimant testified that migraine headaches are so severe that she can only lie down in the dark until they subside. She also testified that the migraines last up to three days. She claimed she was concerned about the side effects from the new drugs but had no choice but to take the medication.

The ALJ denied her application using the standard five-step test outlined in Section 20 C.F.R. §404.1520(a)(4) of the Social Security Act. The ALJ first found that she was no longer at work. He then found that the combination of her impairments qualified as severe under the definitions in the statute. However, at step thee, the ALJ found that she did not meet the durational requirements that would allow her to be automatically qualified for SSDI benefits, and then proceeded to step four of the analysis.

Step four of the disability statute requires a determination of the claimant’s residual functional capacity. In other words, what is the extent that a claimant can still work, given their disability? The ALJ found that she could still do work if she was allowed to sit whenever she needed to do so. It was also determined that she could lift 10 pounds frequently and 20 pounds if it was needed. The ALJ refereed to the headaches as “alleged” and did not appear to consider them at the time he made a finding.

Claimant appealed her denial of disability on grounds that the ALJ did not account for her migraine headaches. On appeal, the court concluded that the judge’s decision to treat the migraine headaches as either fake or non-substantial, and his decision not to include them in his disability analysis, were not supported by evidence. The court said that the ALJ failed to build a logical bridge between the evidence before him and his determination that the claimant was not disabled.

Ultimately, the appellate court held that the ALJ was incorrect, and the case was reversed and remanded for further proceedings consistent with the opinion.

If you are seeking Social Security Disability Insurance in Boston, call for a free and confidential appointment at 1-888-367-2900.

Additional Resources:

Moon v. Colvin, August 21, 2014, U.S. Court of Appeals for the Seventh Circuit

More Blog Entries:

Hanson v. Colvin: A Critical Look by a Court of Appeals on a Denial of Benefits, August 14, 2014, Boston Disability Lawyers Blog